Performance Pricing, Inc. v. Google Inc. et al

Filing 12

DECLARATION of Emily C. O'Brien In Support of MOTION to Compel Production of Documents 1 Supplemental Declaration of Emily C. O'Brien in Support of Defendants' Motion to Compel Production of Documents By Third Parties Neal Cohen and Vista IP Law Group, LLP filed by Defendants Google Inc., AOL LLC. (Attachments: # 1 Exhibit Q)(O'Brien, Emily)

Performance Pricing, Inc. v. Google Inc. et al

Doc. 12

1 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP Charles K. Verhoeven (Bar No. 170151) [e-mail] 2 David A. Perlson (Bar No. 209502) [e-mail] 3 Jennifer A. Kash (Bar No. 203679) [e-mail] 4 50 California Street, 22nd Floor 5 San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
01002.51305/3089044.1

Attorneys for Defendant Google Inc. and 8 AOL LLC UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PERFORMANCE PRICING, INC., Plaintiff, vs. GOOGLE INC. and AOL LLC, Defendants. CASE NO.: CV 09-6283 MMM (CTx) DISCOVERY MATTER [PUBLIC REDACTED] SUPPLEMENTAL DECLARATION OF EMILY C. O'BRIEN IN SUPPORT OF DEFENDANT GOOGLE INC. AND AOL LLC'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY THIRD PARTIES NEAL COHEN AND VISTA IP LAW GROUP LLC Crtrm.: Roybal- 780 Judge: Margaret M. Morrow Hrg. Date: September 21, 2009 Hrg. Time: 9:30 a.m.

CASE NO. CV09-6283-MMM (CTx)

[PUBLIC REDACTED] SUPPLEMENTAL DECLARATION IN SUPPORT OF DEFENDANTS' MOTION TO COMPEL Dockets.Justia.com

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DECLARATION OF EMILY C. O'BRIEN I, Emily C. O'Brien, declare and state as follows: 1. I am an associate of the law firm Quinn Emanuel Urquhart

5 Oliver & Hedges, LLP and represent Defendants AOL LLC and Google Inc. in this 6 action. This declaration is made in support of Defendant Google Inc. and AOL 7 8 LLC's Motion to Compel Production of Documents. The matters referred to in this 9 declaration are based upon my personal knowledge, and if called as a witness I 10 could testify competently to those matters. 11 12 2. Attached hereto as Exhibit Q is a true and accurate copy of the 13 Exclusive License Agreement between Wayne Lin and Acacia Patent Acquisition 14 Corporation, produced by Plaintiff at bates numbers P 02733-02749. This exhibit 15 16 was designated "Confidential-Attorneys' Eyes Only" by Plaintiff under the 17 protective order entered in Performance Pricing, Inc. v. Google Inc. et al., Case No. 18 2:07-cv-432 (LED) (Eastern District of Texas). 19 20 21 22 23 24 25 26 27 28
01002.51305/3089044.1

[PUBLIC REDACTED] SUPPLEMENTAL DECLARATION IN SUPPORT OF DEFENDANTS' MOTION TO COMPEL

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CASE NO. CV09-6283-MMM (CTx)

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01002.51305/3089044.1

I declare under penalty of perjury under the laws of the United States of

2 America that the foregoing is true and correct. Executed on September 4, 2009 at San Francisco, California. /s/ Emily C. O'Brien Emily C. O'Brien

[PUBLIC REDACTED] SUPPLEMENTAL DECLARATION IN SUPPORT OF DEFENDANTS' MOTION TO COMPEL

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CASE NO. CV09-6283-MMM (CTx)